Delhi High Court: In an application filed under Order 39 Rules 1 and 2 of the Civil Procedure Code, 1908, wherein the plaintiff, Karan Johar, sought a permanent injunction restraining Defendants 1 to 13 from infringement of copyright, performer’s rights, misappropriation of Personality Rights and passing off, the Single Judge Bench of Manmeet Pritam Singh, J, held that the unauthorised use of Karan Johar’s persona constituted an infringement of his Personality Rights. Thus, the Court granted interim injunction in favour of Karan Johar and directed blocking and disabling of all infringing websites, platforms and social media accounts disseminating content that violate his Personality Rights
Background
The plaintiff, Karan Johar is an acclaimed producer, director, talk show host and actor. He has produced and directed several critically acclaimed blockbuster films and he exercises great influence in the film industry. In addition to winning several awards, he has also been conferred with the Padma Shri. He has also endorsed multiple well-known national and international brands. It was submitted that the plaintiff’s physical appearance, image and likeness are unique and is a brand in itself. His voice, tone and manner of speech are distinctive aspects of his personality and have an instant recall value.
The plaintiff contended that Defendant 1,referred to as ‘John Doe’, as well as known entities Defendants 2 to 13 used AI to create morphed images, including deep-fake, and audio-video clips that are in bad taste and made the plaintiff a subject of humiliation, disparagement, obscenity and ridicule. He further contended that due to such derogatory and unlawful exploitation of his personality rights, he has suffered a significant loss of goodwill and reputation.
Defendant 1 is the owner of the domain name ‘www.karanjohar.com’ and it was contended that the adoption of such a domain name was obtained with the intent to ride upon the goodwill and reputation of the plaintiff.
Defendant 2 operates a website that allows the public to access and download various images and wallpapers of the plaintiff.
Defendant 3 is the registrar of a website that allows the public to swap the voice of the plaintiff using AI. Defendant 4 is the registrar of a website that contains an AI chatbot which unauthorizedly uses the personality rights of the plaintiff.
Defendants 5 and 6 are online platforms that make and enable users to make Graphical Interchange Format (GIFs) that inappropriately exploit the plaintiff’s name and image.
Defendants 8,9,11,12 and 13 are various online marketplaces and e-commerce websites that have enabled sale of merchandise that unauthorizedly uses the plaintiff’s persona. It was contended that the activities of Defendants 8 to 13 mislead the public to believe that the plaintiff is either associated with or is endorsing the products of the defendants
Analysis, Law and Decision
The Court noted that the videos, memes and social media posts contain abusive and profane words as well as innuendoes, which appear to be offensive. The said content tarnishes the reputation and goodwill of the plaintiff affecting his brand value. Furthermore, the defendants have created fake profiles on various social media platforms that have the potential to mislead the public into believing that the accounts are official or authorized by the plaintiff.
The Court thus held that the plaintiff had established a prima facie case for grant of ex-parte injunction since the balance of convenience was in his favour and if the injunction was not granted, it would cause irreparable damage to the plaintiff’s reputation. Thus, the Court held that the plaintiff was entitled to seek injunction to protect his personality rights against such negative use.
The Court directed Defendants 2, 3, 4 and 7 to suspend and lock the impugned websites and domain names and take down any disparaging content posted on their respective webpages. Defendant 5 was restrained from publishing any material which infringes the personality rights of the plaintiff. Defendants 9 and 13 were restrained from selling or facilitating sale of merchandise which infringes the personality rights of the plaintiff. The said defendants were also directed to delist the disparaging products available on their platforms.
The Court also restrained the John Doe defendants as well as anyone acting on their behalf from utilizing the plaintiff, Karan Johar’s name, his acronym ‘KJo’, likeness, image, voice, personality or any other aspects of his persona to create any merchandise, or in any other manner misuse the said attributes using technological tools such as AI, Machine Learning, deep fakes, face morphing, GIFs either for monetary gains or otherwise to create any videos, photographs, etc., for commercial purposes, so as to result in violation of the plaintiff’s rights.
The matter was further listed for 19-2-2026.
[Karan Johar v. Ashok Kumar, 2025 SCC OnLine Del 6108, decided on 17-9-2025]
Advocates who appeared in this case:
For the Plainiff: Rajshekhar Rao, Senior Advocate, Nizamuddin Pasha, Parag Khandhar, Chandrima Mitra, Krishan Kumar, Sidharth Kaushik, Advocates
For the Defendants: Nirupam Lodha, Kshitiz Parashar, Gautam Wadhwa, Mamta Rani Jha, Rohan Ahuja, Shruttima Ehersa, Diya Viswanath, Aiswarya D., Devangini Rai, Varun Pathak, Yash Karunakaran, Advocates
